## Facts

- Craig E. Tuckman (husband) and Karen R. Tuckman (wife) married in 1990 and had two children.
- Both parties had substantial income and assets.
- The wife held a one-third interest in an investment partnership (BJK Partners) and a one-third interest in a family office-furniture business (Offices Limited, Inc.), generating significant income over multiple years.
- The husband worked in commodities trading with a high base salary and large bonuses, and had an employment arrangement projecting additional compensation.
- The husband filed for dissolution in 2006 seeking dissolution, custody, child support, and educational support; the wife counterclaimed seeking dissolution, alimony, joint custody, child support, educational support, and property division.
- The trial court dissolved the marriage, adopted an agreed parenting plan, entered financial orders, awarded child support, and did not award periodic alimony.
- On the wife’s appeal, the Appellate Court reversed the financial orders and ordered a new trial, concluding the trial court failed to address the child support guidelines and required deviation findings.
- The husband obtained certification to appeal to the Supreme Court, challenging the Appellate Court’s reversal.

## Issues

1. Whether the trial court abused its discretion by awarding child support without applying the Connecticut Child Support and Arrearage Guidelines, without filing the required guidelines worksheet, and without stating on-the-record reasons for any deviation.
2. Whether the trial court properly included the wife’s subchapter S corporation allocated income in her annual net income for purposes of alimony and child support, absent findings on its actual availability.

## Decision

- The Supreme Court affirmed the Appellate Court’s judgment reversing the financial orders and ordering a new trial on those orders.
- The Court held that the trial court abused its discretion by failing to mention or apply the child support guidelines, failing to file the required worksheet, and failing to make specific deviation findings on the record.
- The Court held that, although S-corporation allocated income may be considered in support calculations, the record lacked necessary findings about the corporation and the availability of the allocated income to the wife.
- The Court concluded that remand was necessary to determine what portion of the wife’s S-corporation income constituted available income for alimony and child support purposes.
- The Court agreed that the financial orders were interrelated, supporting a new trial on the overall set of financial orders rather than a limited correction to child support alone.

## Legal Principles

- Child support awards must be grounded in the presumptive child support guidelines; a court must calculate net income, apply the guidelines, and file the required worksheet.
- Any deviation from the presumptive guideline amount must be supported by a specific finding on the record stating why deviation is warranted.
- In higher-income cases, the guidelines remain operative as a presumptive baseline; courts must still articulate the methodology and any deviation.
- Subchapter S pass-through (allocated) income can be included in net income for support purposes only after fact-specific findings about whether the income is actually available to the shareholder spouse (including distribution practices and practical access to funds).
- When child support, alimony, and related financial orders operate as an interdependent set, error in the support methodology can require reconsideration of the entire financial scheme on remand.

## Conclusion

The Supreme Court affirmed an order for a new trial on financial orders because the trial court failed to apply and justify deviations from the child support guidelines and failed to make necessary factual findings about the availability of S-corporation allocated income for support and alimony determinations.


Tuckman v. Tuckman, 308 Conn. 194, 61 A.3d 449 (Conn. 2013)